…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF, VIRGINIA GIUFFRE’S REDACTED BRIEF IN SUPPORT OF THE PRIVILEGE CLAIMED FOR HER IN CAMERA SUBMISSION Plaintiff Virginia L. Giuffre, by…
…The two lawyers alleged that Dershowitz defamed them when he claimed that they knowingly filed a lawsuit containing falsehoods about him or at least failed to properly investigate their client’s allegations that Dershowitz had sexual relations with her when…
…which Ms. Maxwell is a target. First, Plaintiff claimed that the documents were protected by a non-existent “investigative privilege.” When Ms. Maxwell demonstrated that the “investigative privilege” does not exist, Plaintiff threw up the inapplicable “public interest” privilege, the…
…643, 645 (2d Cir.2009) (movant had standing to challenge subpoena to itself and its attorneys because it claimed privilege in the material sought). Here, the Court clearly should grant a protective order barring disclosure of all of Ms. Giuffre…
…26, 2016,,. Plaintif f fi led the ins tant motio n to compel Defendant to respond to interrogatories to which Defendant has claimed the protection of the attorney-client, attorney -cl ie nt-ag ent , and common interest privileges. Oral…
…5), while simultaneously submitting 14,825 pages of relevant materials under seal to the Court. The Government claimed that these pages were “privileged” for various reasons, attaching an abbreviated privilege log. 8. While these discovery issues were pending, in the…
…Plaintiff has been attempting to dodge the production of these documents for months. First, Plaintiff claimed that the documents were protected by a non-existent “investigative privilege.” When Ms. Maxwell demonstrated that the “investigative privilege” did not exist, Plaintiff threw…
…Miami Herald claims to practice. Indeed none of the descriptions of alleged sexual activities or unsupported claims of sex with nonparties would be relevant to the Herald’s claimed investigation of a “cross-border sex-trafficking ring,” Mot. to Unseal…
…643, 645 (2d Cir.2009) (movant had standing to challenge subpoena to itself and its attorneys because it claimed privilege in the material sought). Here, the Court clearly should grant a protective order barring disclosure of all of Ms. Giuffre…
…cross examination, not one. Any standard of truth and were used for those who claimed they were victims to receive financial payment to be shared between them and their lawyers. One firm created and sold fake cases against Mr. Epstein…
…happened. Dershowitz can only do this by offering evidence to the jury that the specific acts of alleged trafficking claimed by Giuffre with the individuals she has affirmatively placed at issue never Case 1:15-cv-07433-LAP Document…
…jury subpoena enforced through an ex parte proceeding before . Although the government claimed not to know what was in file and that had no role in instigating the investigation of Maxwell, both of these representations to were false. In turn…
…in defamation action against Walter Clemens, denying disclosure of sensitive and personal financial information, claimed to be related only to issue of punitive damages, as premature before dispositive motions). In circumstances such as these, the procedure followed in a similarly…
…contents. By way of example, in DE 203 at page 5, Plaintiff’s counsel claimed that Doe 1 citing DE 204-3 at 36-41. In fact, Doe 1 testified in excerpts that were not attached to pleadings that Ex…
…More importantly, the dozens of non-parties who provided highly confidential information relating to their own stories provided that information in reliance on the Protective Order and the understanding that it would continue to protect everything it claimed it would. …
…other employees of” Ms. Maxwell or Jeffrey Epstein. Plaintiff claimed as to her Rule 26 disclosures that “only a fraction of those individuals will actually be witnesses in this case, and as discovery progresses, the list will be further narrowed…
…sealing.” Bernstein v. Bernstein Litowitz Berger & Grossmann LLP, 814 F.3d 132, 136 (2d Cir. 2016). The claimed compelling reasons must be supported by specific factual findings. United States v. Erie Cty., 763 F.3d 235, 236 (2d Cir. 2014)…
…Privilege. 1. Defendant Waived Attorney-Client Privilege by Placing Communications with Her Attorney at Issue. Earlier in this case, Defendant claimed attorney-client privilege over her email communications with Barden. And earlier in this case, this Court uphe…
…June 20, 2016, Order directing Defendant to turn over documents that she improperly claimed as “privileged,” Defendant redacted the public version of the Order to erase all reference to her extensive communications with her boyfriend, convicted pedophile Jeffrey Epstein. While…
…at least one press source claimed to “crack” the redactions to identify witnesses and potential testimony by or 3 https://www.npr.org/2020/10/22/926590153/jeffrey-epstein-update-read-the-deposition-that- ghislaine-maxwell-fought-to-hide 4…